SICCAR POINT

We Say

We're glad they are doing that. We want to know what their role is as it seems a bit unclear.

As for "misleading statements" on our web site, we'll cover them later although we would have expected the courtesy of them telling us where they were. It seems a bit petulent of them but we've come to expect little else.

We Say

This list does not include AGLVs ("Area of Great Landscape Value") or SLAs ("Special Landscape Area") which is the landscape designation of the whole of the Berwickshire Coastal Region and includes the SSSI of Siccar Point. The AGLV or SLA designation gives these areas additional protections over and above normal planning considerations. If SNH cannot comment on these other landscape designations then we will apologise for saying that they can and that they must, but it was a genuine mistake that was suggested by SNH's own literature.

Their guide to landscape definitions was written to help local authorities make decisions about landsape designations. That suggests that if SNH are providing official guidance then they must be a stakeholder in that process, but if they say the have no responsibilities for AGLVs or SLAs then we'll take them at their word.

The word "generally" is important here, because SNH ARE commenting on the wider landscape so they are obviously taking some responsibility for their comments and opinions. Apology withdrawn.

We Say

Anyone who has read SNH's response to Jim Kelley's email would say that this simply isn't true. They did nothing but comment on the wider context and then made these comments part of the official record. This position statement is now denying they have provided advice on the wider context in contradiction of the facts.

If saying there is "[no] significant geological interest or value in that location" isn't making a comment, taking a position, or providing advice, then we don't know what is.

We Say

We've always said the pipeline didn't travel through Siccar Point. There were photographs on our site from the very first day that showed the approximate trench location, and there were links to the application and drawings from the very start too. Once we had the figure from SNH of 150m then we added that too.

SNH are again providing advice and comments on the wider context of the site when their Position Statement says they aren't.

We haven't suggested that this sandstone wave-cut bench illustrate the unconformity, but it is a critical part of the landscape and it is visible to anyone visiting Siccar Point by land. As for not "affect[ing] the geological feature" it's a wooly statement that can be taken all sorts of ways.

Will a trench in this area destroy or damage Siccar Point? Of course it wont. Will a trench affect it? No. Will putting a pipeline in this trench and then use it to pump effluent affect it? Possibly, probably, and maybe, but that's too much of a risk to take without further investigation.

Again, SNH release a statement to clarify, and it does nothing but be selective about the facts and be unclear, leaving it open to interpretation. Rather than clarifying, SNH are obscuring.

We Say

REALLY? What modelling are they referring to? Where's the reference to it or the evidence to support it? The only modelling on the coastline we could find was a study by SNH itself entitled Research, Survey and Monitoring Report #143, Coastal Cells in Scotland: Cell 1 - St Abb's Head to Fife Ness (2000) by DL Ramsay and AH Brampton (pages 25, 26, and 79) and the contents say exactly the opposite of the drivel in their Position Statement.

This report states that in the areas between St Abbs and North Berwick (what they call "sub cell 1a"):

1. There is little interaction of movement of beach sediment along this coast [once stuff lands on a beach or bay it's unlikely to move]
2. Swell wave conditions are dominated by waves generated from between 20 degrees north and 60 degrees north [wave direction is mostly from north-north-east to east-north-east - directly toward Siccar Point from the outflow that's only 150m away]
3. Between St Abbs and Barns Ness the tidal streams run regularly ESE and WNW on the flood and ebb tide [i.e. the tides are parallel to the coast so wash stuff up and down the coastline, not out to sea, and towards Siccar Point on the outgoing tide]
4. The coastline of sub cell 1a [St Abbs to North Berwick) faces north east and as a result can experience severe wave conditions generated in the North Sea [the seas can be rough with regular swells]
5. yearly extreme wave heights exceed +6.23m (20'5"), and yearly extreme sea swell exceeds +3.56m (11'8") (these heights are higher for decadal extremes) [the regular swells can be quite high regularly exceeding 11 feet and sometimes over 20 feet]

While SNH state opinions, and allude to studies in other areas of the Beriwckshire coast, we've given you the facts and the evidence for the area from research.

The only other area where we're aware of a pipeline that SNH have mentioned to someone is the pipeline at Burnmouth. The sea area around there is completely different to that at Siccar Point and comparisons cannot be drawn. SNH's own study, that we cite, is specifically relevant to this location.

What does all it mean for the waste and Siccar Point?

The pipeline is 150m to the east of Siccar Point. Rather than stir up any emotional reactions that the word "effluent" might cause, lets just assume that it is sea water flowing out of the pipe, maybe with some harmless red dye in it just so we can see it. What do the above points mean - taking each point as it comes?

1. If something is washed ashore it is likely to stay in that locaton. So if this red water is washed onto the shore it will stay there for an extended time.
2. Most waves are from the north east so wave action will carry the red water towards Siccar Point, there is no doubt about that
3. If the red water does get caught on the tide then it will be washed up and down the shoreline, not out to sea, but the dominant wave action (from the north east) will wash it towards Siccar Point when the tide is flowing that way, and the swells will lift it up from the layer of water and wash it over Siccar Point. If more red water is added every day, then it will become more and more concentrated in the same coast parallel fashion although diffusion within the water will play a part too in reducing the overall concentration.
4. The seas are quite rough, and the swells mean that waves will regularly crash over Siccar Point itself. We live in the area, about 1 mile south of Siccar Point, and we can hear the waves breaking on the shore on a quiet calm night.

Given all this research, only a fool could conclude that whatever comes out of that pipe is not going to end up on Siccar Point. The outflow is only 150m away to the east, and all the tidal processes in that area are going to wash whatever comes out of that pipe directly onto Siccar Point.

What matters then is the dilution ratio of the effluent, and the contents of the effluent itself, as there's no doubt at all about where some of it will end up. Extensive modelling will be required to know the quantities, but not the location.

What about the effluent being diluted and dispersed?

There have been 3 objections from what could be considered experts in waste water treatment. One was a retired senior civil engineer who specialised in waste water treatement and disposal, one was a doctor in the School of Environmental Sciences at the University of Liverpool with expertise in this area, and the other was a lecturer in the Department of Earth and Environmental Sciences at the University of St Andrews. All of them have expressed concens about the pipline itself, the effluent, and the ability of the location to properly disperse the effluent to the correct standards.

SEPA require at 50x dilution 95% of the time. As one of these experts said said:

"[this] will not happen, as the discharge point is not far offshore and no dispersion investigations have been carried out. There is therefore a potential risk of back eddies and onshore winds creating a localised anoxic area in the area immediately around the outfall to the detriment of any marine life.".

Another said:

" Might agricultural waste released below MLWS and diluted to >50x, 95% of the time, or else the up-to-5% of agricultural waste which is not 50x diluted, be transported by the tide ~100 m toward Siccar Point and then washed onto the rock outcrops of scientific interest by breaking storm waves?

It feels like the answer is "possibly" or "probably", either of which are unsatisfying for conserving "literally" the world's most historically famous rock outcrop. "

They also said

" SNH's Research, Survey and Monitoring Report #143, Coastal Cells in Scotland: Cell 1 - St Abb's Head to Fife Ness (2000) by DL Ramsay and AH Brampton is relevant to modeling these possible scenarios that would foul the Siccar Point outcrop.

That report notes that both flood and ebb tidal flow around Siccar Point is coast-parallel; that dominant offshore waves are from the northeast; and that nearshore waves are likely to come from the ENE. All of these factors seem likely to transport agriculatural debris from the proposed effluent discharge pipe toward Siccar Point and keep it for hours to days in the coastal zone affected by breaking waves. Report #143 also notes that yearly extreme wave heights exceed +6 m, and yearly extreme sea swell exceeds +3.5 m (these heights are higher for decadal extremes).

It seems as though these tidal and wave conditions could easily litter the Siccar Point outcrop with unsightly, smelly debris that would obscure scientifically important characteristics of the outcrop. "

and:

" In SEPA's ref PCS/121554, the section on dilution to 50x for 95% of the time specifically does not address the availability of under-diluted, or else diluted-but-still-suspended debris being redeposited on Siccar Point by tides and waves. That SEPA advisory notes that the applicant had not, by 16 Aug, informed SEPA of the levesl fo Faecal Coliforms in the discharge; faecal coliform bacteria are even more likely to remain suspended for an extended duration in the water. "

Another said:

Pollution of the marine site. This is likely to lead to localised eutrophication and certainly to disruption of the local ecology, and probably the eradication of the ecosystem at the pipe's end. Downstream there can be expected an increase in production, which could be beneficial to some species, but the overall net benefit is highly dubious and can only be estimated with any confidence after detailed research.

All of the above are writing from a position of expertise and authority and completely disagree with SNHs conclusions.

Will the existing effluent change in composition and character?

Although it is not specifically addressed in the SNH Position Statement, we are assuming (rightly or wrongly) that SEPA and SNHs opinions are predicated on the current effluent composition.

We alluded on our web site that Drysdales were planning to remove parts of their exsting waste processing facilities, and despite being quick to address "significant inaccuracies" in our web site (that were never proved) they never denied what was said about removing parts of their exisitng waste water processing. This was also suggested by the objector TA Dykes. It would also be fair to say it was common knowledge in the local area that these are Drysdales' plans as we've heard if from several people.

If it is clear from the available evidence opposed to unsupported opinions that this effluent (whatever it's composition) is going to end up on Siccar Point. Serious doubts have also been expressed by people with knowledge about waste disposal whether SEPAs dilution ratios will be achieved or that sufficient dispersion will occur. Even so, what will be the most critical factor is the effluent itself. If it remains in it's current composition the effects on Siccar Point are likely to be minor and unobjectionable, but if the effluent changes to one which is less palatable the effects on Siccar Point increase too.

If the effluent character does change then does that make a difference to the 50x dilution ratio SEPA require? Will it require higher dilution ratios? Given that there are doubts about the current proposal's ability to achieve even the basic 50x dilution ratio then this raises even more concerns. It is also worth considering that SEPAs recommendations for pipe depth have not been modelled.

Therefore, it is important to consider not just the effluent as it is now, but the effluent character as it may become, because if the pipeline is approved, and the effluent does change, it might be too late to do anything about it.

Assuming the pipeline is approved, if Drysdales decide to change their existing treatment processes it would only be a matter for SEPA. SEPA would consult other stakeholders such as SNH, the Council, and local Community Councils, but direct public comment would not be as easy as it is with planning applications.

There have also been objections by two people who have extensive knowledge of the effluent characteristics before the reed bed were installed. TA Dykes said "I was relieved when the reed beds were installed". Another from Mr R Turner was perhaps more forthright in his condemnation when he said "The effluent from this site was once poured into a stream passing through it, and it converted the stream into a very foul smelling sewer. However, the problem was dealt with very successfully by installing a reed bed, and the water in the stream has now been clear for many years". We're sure no-one wants this to happen again....and don't forget....THAT effluent was LICENCED by SEPA too. Do you really want that coming out of the pipe near Siccar Point?

We Say

The depth is 600mm according to the plans and this is the second time they've said this. The "slightly recessed" is a new statement they haven't made before, but it doesn't change the fact that this is going to look like a concrete trench no matter what they say. It's incredible that they aren't taking measurements from what the plan shows.

We Say

We've been over this one before on our site, and it simply isn't true with regards to this platform.

What outflows are they talking about [citation!]? We're aware of two that we see regularly although we are sure there are more - but none of them, as far as we are aware are for industrial waste water. The one on Eyemouth beach is a concrete encased pipe that continues to look exactly like a concrete-encased pipe. There is also a pipeline at Burnmouth that is "softened" but still obvious, but the whole foreshore there is covered in thick seaweed unlike the platform east of Siccar Point. Is this statement SNH being intentionally misleading to bolster their opinion rather than give the facts?

Are SNH providing advice and an opinion outside the SSSI that their own Position Statement says they have not done?

We Say

Well of course not, digging the trench isn't going to cause the whole coastline to crash and crumble into the sea, but that is missing the point.

The rest of their comments have been shown to lack any evidence at all while our opinions are based on research (that we have referenced so you can check for yourself) and what is visible at the location now.

Once again SNG commenting and providing advice on the pipeline route by suggesting that the location has no "special features". Why do they insist on saying that they can't and that they aren't commenting or providing advice outside the SSSI, then go ahead and do so?

Given what has been said, it seems that SNH could hardly be said to be a neutral and impartial source of comment. If this is the quality of what they produce - incorrect figures, opinions not backed up by the facts, studies mentioned in support of their comments but no references or citations given so they can be checked, their own published studies show the exact opposite of what they write, and referring to "other pipelines" but not even mentioning where they are - then it's a poor defence of an untenable position.